2024 (5) TMI 1681

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.... For the Petitioner : Mr. Sumit Lalchandani & Mr. Tarun Chanana, Advs. For the Respondents : Mr. Gaurav Gupta, SSC with Mr. Shivenda Singh, Mr. Yojit Pareek, JSCs & Mr. Namit Gupta, Adv. ORDER 1. These writ petitions have been preferred against the impugned notices dated 29 June 2022 issued under Section 153C of the Income Tax Act, 1961 ["Act"] for Assessment Years' ["AYs'"] 2016-17 [W....

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....id decision read as under:- ""G. Insofar as the thresholds put in place by virtue of the Fourth Proviso to Section 153A are concerned and the argument of the writ petitioners of the condition of INR 50 lakhs being an unwavering precondition, we find ourselves unable to sustain that submission bearing in mind the indubitable fact that proceedings for search assessment commence upon the iss....

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....d at the same time, even if the identified asset at that stage be quantified as less than INR 50 lakhs, the AO must for reasons to be duly recorded, be of the opinion that the ultimate computation of escaped income is likely to exceed INR 50 lakhs. The aforesaid satisfaction would have to be based on an assessment of the material gathered and the potentiality of the same being indicative of the es....